Code of Ethics

Senior Financial Officers’ Code of Ethics

This Senior Financial Officers’ Code of Ethics (the “Code”) has been adopted by the Board of Directors (the “Board”) of Raymond James Financial, Inc. (the “Company”) to promote honest and ethical conduct, proper disclosure of financial information in the Company's periodic reports, and compliance with applicable laws, rules and regulations by the Company's senior officers who have financial responsibilities.

As used in this Code, the term “Senior Financial Officer” means the Company's Chief Executive Officer, Chief Financial Officer, Chief Accounting Officer, and Controller.